Aaron Jacob Greenspan v. Elon Musk, et al.

District Court, N.D. California·Decided December 19, 2025·No. 3:24-cv-04647·Unknown

Opinion

AARON JACOB GREENSPAN, Case No. 24-cv-04647-MMC

Plaintiff, ORDER DENYING PLAINTIFF’S v. MOTION FOR REVIEW AND REVERSAL OF CLERK’S COSTS ELON MUSK, et al., AWARD Defendants.

Before the Court is plaintiff Aaron Jacob Greenspan’s (“Greenspan”) Motion, filed November 8, 2025, “for Court Review and Reversal of Clerk’s Costs Award.” Defendants Elon Musk, Tesla, Inc. (“Tesla”), the Elon Musk Revocable Trust dated July 22, 2003, Excession, LLC, Jared Birchall, Singer Cashman, LLP, Allison Huebert, Adam S. Cashman, Adam G. Mehes, and Alex Spiro have filed opposition, to which Greenspan has replied. Having read and considered the papers filed in support of and in opposition to the motion, the Court rules as follows.1 By the Court’s prior order, filed July 17, 2025, Greenspan’s federal claims were dismissed with prejudice and his state law claims were remanded to state court (see Order Re Motions to Dismiss at 16:11-12 (Doc. No. 156)), whereafter Tesla filed a Bill of Costs for the $405 filing fee it paid on removal of the instant action (see Doc. No. 160), and the Clerk of Court taxed costs in that amount (see Doc. No. 174). By the instant motion, Greenspan asks the Court to “review the Clerk of Court’s award of costs . . . and reverse or vacate such award.” (See Mot. at 1:7-9.) In support of that requested relief, Greenspan makes the following four arguments: (1) removal was improper; (2) Tesla is not the prevailing party; (3) the removal fee was not “necessarily incurred”; and (4) equitable factors weigh against an award of costs. (See id. at 4-11.) The Court addresses each such argument in turn. First, Greenspan argues, “a court should not award costs to the removing party when removal was improper” and that “[t]hrough its ruling in ECF No. 156, this Court thus ruled that Defendant Tesla’s removal to this Court was improper as this Court lacked jurisdiction over any portion of plaintiff’s original complaint—the version of the complaint that was actually removed to federal court on July 31, 2024.” (See Mot. at 4:26-5:12) (internal quotation, citation, and alteration omitted). Although Greenspan is correct that the Court, in the order to which he refers, found the state law claims comprising his initial Complaint did not raise a federal question, the Court issued no ruling as to the propriety of the removal, as Greenspan, rather than filing a motion to remand, filed an Amended Complaint adding a federal claim under the Racketeer Influenced and Corrupt Organizations Act (“RICO”) (See Doc. No. 55), thereby conferring federal jurisdiction over the case, see 28 U.S.C. § 1331, and electing to have his claims proceed in federal court. Second, Greenspan argues, Tesla is “not the ‘prevailing party’ for the purposes of Rule 54(d)(1)” of the Federal Rules of Civil Procedure (see Mot. at 5:19-22), under which, “[u]nless a federal statute, [said] rules, or a court order provides otherwise, costs—other than attorney’s fees—should be allowed to the prevailing party.” See Fed. R. Civ. P. 54(d)(1). In support thereof, Greenspan points out that the Court dismissed only his RICO claim, whereas his state law claims were remanded, the Court declining to exercise supplemental jurisdiction over the state claims once the sole federal claim was dismissed. (See Doc. No. 156 at 15:1-12.) The Ninth Circuit has held, however, that a defendant that prevails on a plaintiff’s federal claims is the prevailing party even though the court declines to exercise supplemental jurisdiction over such plaintiff’s state law claims and, after either dismissal or remand, depending on where those claims initially were filed, allows them to proceed in state court. See San Diego Police Officers’ Ass’n v. San Diego City Employees’ Ret. Sys., 568 F.3d 725, 732, 742 (9th Cir. 2009) (holding remaining against them in the district court, [defendants] were clearly the prevailing parties” and, “[a]s such, they were entitled to the award of costs decreed by the district court”); see also Wade v. Reg’l Credit Ass’n, 87 F.3d 1098, 1101 (9th Cir. 1996) (holding “[w]here a district court dismisses a federal claim, leaving only state claims for resolution, it should decline jurisdiction over the state claims and dismiss them without prejudice”). Third, Greenspan, argues, “the removal fee was not ‘necessarily incurred’” because Tesla elected to remove this action from state court. (See Mot. at 7:13-26); see also 28 U.S.C. § 1924 (providing “[b]efore any bill of costs is taxed, the party claiming any item of cost or disbursement shall attach thereto an affidavit . . . that such item . . . has been necessarily incurred”). A number of district courts, however, have found such argument “without merit.” See Rezaipour v. Cnty. of Los Angeles, 2015 WL 13762921 at *2 (C.D. Cal. Feb. 3, 2015) (holding “[f]ees for removal are taxable as costs”) (collecting cases).2 Lastly, Greenspan argues, “the five primary factors enumerated in Escriba v. Foster Poultry Farms, Inc., 743 F.3d 1236, 1247-48 (9th Cir. 2014)[,] clearly weigh against awarding costs in this action.” (See Mot. at 9:8-11.) In Escriba, the Ninth Circuit held Rule 54(d)(1) “creates a presumption in favor of awarding costs to a prevailing party, but vests in the district court discretion to refuse to award costs.” See id. at 1247-48 (holding “[a]ppropriate reasons for denying costs include: (1) the substantial public importance of the case, (2) the closeness and difficulty of the issues in the case, (3) the chilling effect on future similar actions, (4) the plaintiff’s limited financial resources, and (5) the economic disparity between the parties.” Here, as to the first and third factors, although Greenspan contends the case could

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